I have two questions:

1.   Are any cities incurring the expense of putting homeless up in hotel rooms (either because they are positive or just bc they are seen as "high risk") and if you are incurring that expense, do you know if you can claim that as an allowable expense with the FEMA funds?
   

2.   If you are putting homeless up in hotels, what is the timeline for how long they get to stay and how are you addressing them not acquiring residential tenant rights (which then requires an eviction proceeding)?
   

[Description: cid:image001.jpg@01C9DE0F.9A59EC70]_____________________________________________________________________________________________________
Laura S. Burton  | Police Attorney
City of Gastonia Police Department | 200 East Long Avenue | P.O. Box 1748  | Gastonia, NC  28053
704-866-6962 ph | 704-866-6892 fax | burton_laura@cityofgastonia.commailto:burton_laura@cityofgastonia.com | www.gastoniapd.orghttp://www.gastoniapd.org
Confidential and Privileged Communication: This email is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is privileged or confidential or otherwise legally exempt from disclosure. If you are not the intended recipient, you are not authorized to read, print, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately at the contact information listed in this email.

The City has looked into putting homeless individuals in hotel rooms.  Try exploring whether it is reimbursable under FEMA as non-congregate shelter.  There may also be some provisions under the CARES Act that may apply as well as other federal grants related to COVID-19 that might cover the expense.

Deidra Penny
Deputy City Attorney & First Assistant City Attorney
City of Houston Legal Department
Deidra.Penny@HoustonTx.govmailto:Deidra.Penny@HoustonTx.gov
832.393.6246tel:832.393.6246 (O)

The information contained above or attached is privileged and/or confidential. If you received this data in error, please notify me, destroy all copies immediately and do not copy or distribute the information.

From: Disasterrelief disasterrelief-bounces@lists.imla.org On Behalf Of Burton, Laura
Sent: Tuesday, April 14, 2020 1:59 PM
To: disasterrelief@lists.imla.org
Subject: [Disasterrelief] Putting homeless up in hotel rooms

[Message Came from Outside the City of Houston Mail System]
I have two questions:

1. Are any cities incurring the expense of putting homeless up in hotel rooms (either because they are positive or just bc they are seen as “high risk”) and if you are incurring that expense, do you know if you can claim that as an allowable expense with the FEMA funds?

2. If you are putting homeless up in hotels, what is the timeline for how long they get to stay and how are you addressing them not acquiring residential tenant rights (which then requires an eviction proceeding)?

[Description: cid:image001.jpg@01C9DE0F.9A59EC70]_____________________________________________________________________________________________________
Laura S. Burton  | Police Attorney
City of Gastonia Police Department | 200 East Long Avenue | P.O. Box 1748  | Gastonia, NC  28053
704-866-6962 ph | 704-866-6892 fax | burton_laura@cityofgastonia.commailto:burton_laura@cityofgastonia.com | www.gastoniapd.orghttps://gcc01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.gastoniapd.org%2F&data=02%7C01%7CDeidra.Penny%40houstontx.gov%7C03b1120c8a6943fb400508d7e0a60b9a%7C57a85a10258b45b4a519c96c7721094c%7C0%7C0%7C637224876081935758&sdata=mqQCEqypDp6yYPmiJh4FAsZqZMuySu2TGrgCa6hmDrY%3D&reserved=0
Confidential and Privileged Communication: This email is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is privileged or confidential or otherwise legally exempt from disclosure. If you are not the intended recipient, you are not authorized to read, print, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately at the contact information listed in this email.

Hi Laura:

NC has received approval from FEMA for non-congregate sheltering so you don't need FEMA preapproval (a copy of the state's approval is attached).  However, there is specific guidance on the requirements for reimbursement eligibility, timeframe for FEMA's preapproval, and reporting requirements.  Please route your questions through your county emergency manager to Steve Powers with NCEM for more specific guidance and to coordinate your efforts.

Stay safe!
Norma

[http://www.sog.unc.edu/dailybulletin/images/SOGLogoForEmail.gif]Norma R. Houston
Lecturer in Public Law and Government
The University of North Carolina at Chapel Hill
Campus Box 3330, Knapp-Sanders Building
Chapel Hill, NC 27599-3330
T: 919.843.8930
www.sog.unc.eduhttp://www.sog.unc.edu/

E-mails sent to or from this e-mail address that relate to the School of Government's work are public records and may be subject to public access under the North Carolina public records law.

From: Disasterrelief disasterrelief-bounces@lists.imla.org On Behalf Of Burton, Laura
Sent: Tuesday, April 14, 2020 2:59 PM
To: disasterrelief@lists.imla.org
Subject: [Disasterrelief] Putting homeless up in hotel rooms

I have two questions:

1. Are any cities incurring the expense of putting homeless up in hotel rooms (either because they are positive or just bc they are seen as "high risk") and if you are incurring that expense, do you know if you can claim that as an allowable expense with the FEMA funds?

2. If you are putting homeless up in hotels, what is the timeline for how long they get to stay and how are you addressing them not acquiring residential tenant rights (which then requires an eviction proceeding)?

[Description: cid:image001.jpg@01C9DE0F.9A59EC70]_____________________________________________________________________________________________________
Laura S. Burton  | Police Attorney
City of Gastonia Police Department | 200 East Long Avenue | P.O. Box 1748  | Gastonia, NC  28053
704-866-6962 ph | 704-866-6892 fax | burton_laura@cityofgastonia.commailto:burton_laura@cityofgastonia.com | www.gastoniapd.orghttp://www.gastoniapd.org
Confidential and Privileged Communication: This email is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is privileged or confidential or otherwise legally exempt from disclosure. If you are not the intended recipient, you are not authorized to read, print, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately at the contact information listed in this email.

Excellent, thanks!  And thanks for the other responses too.

From: Houston, Norma [mailto:nhouston@sog.unc.edu]
Sent: Tuesday, April 14, 2020 3:31 PM
To: Burton, Laura; disasterrelief@lists.imla.org
Subject: RE: Putting homeless up in hotel rooms

CAUTION:  This email originated from outside of the organization.  Do not click links or open attachments unless you recognize the sender and know the content is safe.
Hi Laura:

NC has received approval from FEMA for non-congregate sheltering so you don't need FEMA preapproval (a copy of the state's approval is attached).  However, there is specific guidance on the requirements for reimbursement eligibility, timeframe for FEMA's preapproval, and reporting requirements.  Please route your questions through your county emergency manager to Steve Powers with NCEM for more specific guidance and to coordinate your efforts.

Stay safe!
Norma

[http://www.sog.unc.edu/dailybulletin/images/SOGLogoForEmail.gif]Norma R. Houston
Lecturer in Public Law and Government
The University of North Carolina at Chapel Hill
Campus Box 3330, Knapp-Sanders Building
Chapel Hill, NC 27599-3330
T: 919.843.8930
www.sog.unc.eduhttp://www.sog.unc.edu/

E-mails sent to or from this e-mail address that relate to the School of Government's work are public records and may be subject to public access under the North Carolina public records law.

From: Disasterrelief <disasterrelief-bounces@lists.imla.orgmailto:disasterrelief-bounces@lists.imla.org> On Behalf Of Burton, Laura
Sent: Tuesday, April 14, 2020 2:59 PM
To: disasterrelief@lists.imla.orgmailto:disasterrelief@lists.imla.org
Subject: [Disasterrelief] Putting homeless up in hotel rooms

I have two questions:

1. Are any cities incurring the expense of putting homeless up in hotel rooms (either because they are positive or just bc they are seen as "high risk") and if you are incurring that expense, do you know if you can claim that as an allowable expense with the FEMA funds?

2. If you are putting homeless up in hotels, what is the timeline for how long they get to stay and how are you addressing them not acquiring residential tenant rights (which then requires an eviction proceeding)?

[Description: cid:image001.jpg@01C9DE0F.9A59EC70]_____________________________________________________________________________________________________
Laura S. Burton  | Police Attorney
City of Gastonia Police Department | 200 East Long Avenue | P.O. Box 1748  | Gastonia, NC  28053
704-866-6962 ph | 704-866-6892 fax | burton_laura@cityofgastonia.commailto:burton_laura@cityofgastonia.com | www.gastoniapd.orghttp://www.gastoniapd.org
Confidential and Privileged Communication: This email is being sent by or on behalf of a lawyer. It is intended exclusively for the individual or entity to which it is addressed. This communication may contain information that is privileged or confidential or otherwise legally exempt from disclosure. If you are not the intended recipient, you are not authorized to read, print, copy or disseminate this message or any part of it. If you have received this message in error, please notify the sender immediately at the contact information listed in this email.